This spring, two high-level Calgary police officials and a City of Calgary bylaw employee flew to Stockholm for a closer look at the Nordic model of prostitution and whether it could work on Canadian streets.

The first thing they realized is that a uniform Nordic model of prostitution doesn’t exist.

Instead, the group found a tangle of legislation, social strategy and enforcement, and an issue that remains as divisive and controversial in Nordic countries as it does here.

“It’s not simple,” said Debi Perry, who was one of the three people who travelled to study prostitution in Sweden, Norway and Denmark in March.

“Even though ‘the Nordic model’ sounds pleasant, the solutions are very complicated,” said Perry, who is manager of the Calgary police strategic services division.

The idea of the so-called “Nordic model” came into the spotlight in Canada after the Supreme Court struck down prostitution laws last December and gave the government a year to come up with new legislation. Justice Minister Peter MacKay has said that this legislation will be a “Canadian solution,” and there’s been broad presumption that it may be some version of the Nordic approach, which criminalizes the trafficking and purchase — but not the sale — of prostitution.

Academic May-Len Skilbrei, who has studied the sex trade for 20 years and co-wrote a book, Prostitution Policy in the Nordic Region (2013), says there’s no clear Nordic model because there are significant variations in how sex purchase is dealt with in the Nordic countries.

The legislation, she says, is deeply affected by social policies in each country, and immigration laws, social services and education may all have more impact on the state of sex work than the actual legislation.

“This has to do with a kind of legal optimism — believing that if you just get a law in place, then everything will be fine, which is rarely the case,” Skilbrei said from her office in Norway.

In 1999, Sweden became the first country in the world to enact legislation against the purchase, but not the sale, of sexual services. The law was seen as the culmination of decades of work on issues of gender equality, feminism and violence toward women.

The law was followed in 2008 with a 36-point strategy heavily weighted toward research and preventive measures. The plan included helping men who buy sexual services, devoting more resources to women at risk of entering the sex trade, increasing resources for police and prosecutors, and studying attitudes toward sexual exploitation ­— including how the issue is seen by young people.

Other Nordic countries later followed the Swedish model, but with variations.

In 2010, Swedish Chancellor of Justice Anna Skarhed led an evaluation of sex-purchase laws from 1999 to 2008 and concluded that the ban on the purchase of sexual services “had the intended effect” and was “an important instrument in preventing and combating prostitution.”

Kasja Wahlberg, Sweden’s National Rapporteur on Trafficking in Human Beings, said around the same time that the number of men buying or trying to buy sexual services had decreased “considerably” under the law. She said conversations caught on police wiretaps showed organized crime groups were focusing on moving sex trafficking operations to countries where prostitution was legal or more tolerated.

Until recently, Skilbrei says, the focus in the Nordic region was on the roots of prostitution, seeing it as a symptom rather than the cause of other social problems. She said the efforts in Norway — which included generous welfare provisions and helping women find other ways to earn a living — have succeeded in keeping Norwegians out of the sex trade, but now the women in prostitution are mainly from countries like Nigeria and Eastern European nations, which presents its own complications and problems.

Skilbrei says responding to these deeper issues is both the key and the challenge.

“Prostitution is not managed by prohibition laws alone,” she said.

If the Nordic model is seen to work, Skilbrei says it’s because the approach mirrors pre-existing public opinion about prostitution in Nordic countries, which may not be the same in a different social environment.

“To buy sex has been considered a problematic act in the Nordic countries, particularly Norway and Sweden, for a long time already. These laws are not driving change, but rather come as a result of already existing attitudes toward prostitution,” she said.

“If a law is exported to a context where people view the phenomenon very differently, where the welfare options are very different, it will produce different effects.”

And whether prostitution legislation in Nordic countries can be considered successful is still a matter of much debate. Sex work has moved off the streets in recent years, and full study of its participants is all but impossible. Success and failure are hard to define, and even harder to measure.

A 2012 study by Pro Sentret, a help centre for prostitutes in Oslo, Norway, painted a dim view of the situation. The Dangerous Liaisons report found women in the country’s sex trade were still experiencing high levels of violence after the Norwegian sex-purchase law was introduced, and that discrimination against women in prostitution had increased under the legislation.

During the Calgary team’s visit to Sweden, Perry said a street lawyer described prostitution to her as a “wicked problem,” a social policy term for issues so complex they are virtually unsolvable.

“It’s one where there is no right answer, where there are lot of complexities to it, where a lot of people have different perspectives and different views,” Perry said.

“I think every country is experiencing that, and that phrase really does highlight, from a social-development perspective, how difficult this problem really is.”

Perry points out that all the Nordic countries are currently looking at reviewing their prostitution legislation. Countries like Germany and Holland, which have moved to full decriminalization and regulation, are considering a review of their laws too.

“I think it was a really good reminder that you can’t just read a document and say, ‘Oh, they have a perfect answer,’ ” Perry said. “Nobody has a perfect answer to this, or life wouldn’t be the way it is.”

The Canadian government has not released a timeline for the new legislation. Justice Department spokesperson Paloma Aguilar said in an e-mail that it would happen “in due course.”

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